As you all likely know, the proposed rule for Meaningful Use Stage 3 is up for comment.
Overall, CMS has tried to simplify the rules by combining the measures and unifying the attestation periods for all participants. This would mean eligible hospitals (EH) and critical access hospitals (CAH) would no longer attest under different rules than eligible physicians (EP). While not finalized, there are a number of changes to the transition of care requirements.
Care Transitions Definition Refined
CMS has included previous clarifications and added new ones to their definition of a transition of care. A transition of care is still the movement of a patient from one care setting to another where there is the expectation of follow-up care. However, referrals will now also be included under the rule. Referrals are when a patient sees another provider, but the initial provider continues to care for the patient as well. As long as this other provider is a separate billing entity, CMS will count the referral as a transition of care.
Summary of Care Clarifications
CMS has also addressed confusion around providers simply accessing the previous care setting's EMR to get the patient's record. While CMS supports the ability of providers to do this, they have also noted that a transition summary must still be sent to the follow-up care setting. The rationale behind this recommendation is that the summary of care information is more tailored to the needs of the clinicians in the next level of care and that simply accessing the EMR does not support the workflow of those clinicians.
Stage 3 Transition of Care Requirements
Here's a look at the proposed transition of care requirements for Stage 3, compared to Stage 2:
- CMS has eliminated the requirement that participants provide a paper-based Summary of Care document for 50% of patient transitions. CMS still recommends offering this service to patients, but will no longer count it for attestation.
- CMS has raised the bar on electronic transfers of Summary of Care records by increasing the percentage of patients that must receive one from 10% of patient transitions to 50%.
CMS has also added 2 new requirements.
- When a provider receives a new patient, the provider must incorporate that patient's electronic record into the provider's CEHRT for 40% of those inbound transitions/referrals.
- In more than 80% of transitions of care, the provider must conduct a "clinical information reconciliation," which not only includes medications and allergies, but problems as well.
ONC Technical Requirements Expanded
The transitions of care requirements for the proposed rule have increased in difficulty. In addition, the ONC is seeking to expand the technical requirements as well, including the expansion of the CCDA to CCDA R2. The new CCDA includes additional elements key to post-acute care providers including:
- Care Plan
- Referral Notes
- Transfer Summary
- Mental Status
- Physical Findings
- Finding of Skin
- Wound Observation
Optimistic Transition of Care Requirements
Combining measures and time periods in the new rule will streamline meaningful use program for participants. However, the industry is still struggling with the care transition measures set in Stage 2, so increasing transitions of care requirements in Stage 3 seems very optimistic on the part of CMS, even with a 2018 deadline. In addition, post-acute providers are still omitted from meaningful use despite the ONC's updated CCDA rules that aim to provide better support for post-acute providers.
Eric Chetwynd, Director of Product Strategy at Curaspan, ensures that the company continues to deliver solutions that best meet the customers' needs while maintaining the company's position as the market leader in care transitions. He brings more than 15 years of experience creating and leading products to market to his role as the director of product strategy. Prior to joining Curaspan, he helped several healthcare technology companies meet the needs of care management organizations, payer organizations, hospitals, physicians and healthcare consumers. These included Ingenix (OptumInsight), PatientKeeper and IHCIS. Eric holds a BA in Vocal Performance and Music Business from University of Massachusetts Lowell.
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